Comment from Eric Scheel

If this rule is adopted, the amount of scup being fished from federal waters of the Northeast will increase dramatically. The change appears positive because the summary declared that it would “permit greater commercial and recreational harvest opportunity while preventing overfishing on the scup stock.” After reviewing further, it became clear that the proposed rule change would put the scup population nearer to the maximum sustainable yield level of 35.60 million lbs. by increasing the catch to 31.92 million lbs. The increase also places the increased yield in the commercial sector much more so than the recreational. According to the rule, the approx. 5 million lb. increase in commercial allowance could increase a single vessel’s income by an exorbitant 21,432$. The recreational fishing of scup is only proposed to increase by approx. 1.4 million lbs. to 5.74 million lbs. However, in 2010, the actual catch was already at 5.74 million. So, to the recreational fishing of scup, there will likely be no increase. Although this rule reportedly would, “permit greater commercial and recreational harvest…”, it is only applying greater harvest to commercial fishing of scup. A remedy to this may be to shift the increased allowance away from the commercial fishing industry towards recreational fishing. Another fault in the proposed rule is the black sea bass portion. The rule calls for a 41% reduction in the amount (per lb.) of black sea bass landed by recreational fishermen. Even understanding that state practices will greatly influence the actual outcome of this rule, the 41% decrease is such a dramatic drop that some measure of declination should occur over time. It is also unclear how a season change and half an inch size requirement will actually change the catch, while there remains a 25 fish per person possession limit that could potentially still be filled in the same manner as in 2010. Reducing the per person possession limit appears to be a better solution.